2025 (5) TMI 1793

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....ER KAVITHA RAJAGOPAL, J M: This appeal has been filed by the assessee, challenging the order of the learned Commissioner of Income Tax (Appeals) ADDL/JCIT(A)-2 Noida ('ld. CIT(A)' for short) passed u/s. 250 of the Income Tax Act, 1961 ('the Act'), pertaining to the Assessment Year ('A.Y.' for short) 2017-18. 2. The solitary ground involved in this appeal is the disallowance of claim of deduc....

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....commercial bank by relying on the decision of the Hon'ble Apex Court in the case of in Totgar's cooperative sale society Ltd. V. ITO [2010]322 ITR 283(SC). The ld. AO had passed the assessment order u/s. 143(3) of the Act dated 11.12.2019, determining total income at Rs. 15,19,506/-. 4. Aggrieved the assessee was in appeal before the first appellate authority challenging the impugned addition....

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....op. Hsg. Soc. Ltd. vs. DCIT [2024] 167 taxmann.com 153(Gujrat) iv. Brahmarshi Co-op. Credit Society Ltd. vs. ACIT [2025] 170 taxmann.com 336 (Gujrat). 7. Having heard the rival submissions and perused the materials available on record. The only issue that requires adjudication is whether the assessee is entitled to claim deduction u/s. 80P(2)(d) of the Act towards the interest income received f....

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....rom the definition of co-operative societies by the said amendment to Section 194A(3)(v) of the Act, vide Finance Act, 2015 which on perusal is that the co-operative banks are liable to deduct TDS for the interest income on securities made by the co-operative society and not for other interest income made by the co-operative societies. Further, the Hon'ble High Court of Gujrat in the case of Princ....